Cr 16

Net Positive is a new approach
to doing business. To succeed,
business must do more than
minimise its negative impact –
it must be designed to have a
positive impact on the world.
Version 1.1 February 2013
Handbook for factories in India
A guide to Kingfisher Standards for factory working conditions

ii Handbook for factories in India A guide to Kingfisher Standards for factory working conditions Version 1.1 February 2013
Contacts for Operating Companies and Overseas
Sourcing Offices Offices* around the world
Company or Sourcing Office* contact number
B&Q China +86 21 5059 0088
B&Q UK +44 (0) 23 8069 0000
Brico Dépôt France +33 (0) 1 69 63 05 00
Brico Dépôt Spain +34 (0) 93 664 68 18
Castorama France +33 (0) 3 20 16 75 75
Castorama Poland +48 22 575 3100
Castorama Russia +7 (495) 777 2 555
Kingfisher plc +44 (0)20 7372 8008
Kingfisher Asia, Hong Kong* +852 3913 9000
Kingfisher Asia, Shanghai* +86 21 5059 0011
Kingfisher Sourcing Eastern Europe* +48 22 334 90 00
Kingfisher Sourcing India* +91 (11) 46005700
Kingfisher Sourcing South America* +55 3233 4664
Kingfisher Asia Limited (KAL) Vietnam +84 3 541 3626
Koçtas +90 216 430 0300
Screwfix +44 (0)1935 414 100

iii Handbook for factories in India A guide to Kingfisher Standards for factory working conditions Version 1.1 February 2013
Handbook for factories in India
A guide to Kingfisher Standards for factory working conditions
Contents
Introduction to the Kingfisher Group plc 1
Part 1 Why are good factory conditions important? 3
Part 2 Kingfisher’s Standards 8
Part 3 How to use this handbook 10
Part 4 What Kingfisher want to see in your factory 12
1. Management attitude and co-operation 12
2. Age of workers 13
3. Forced labour 16
4. Hours of work 18
5. Wages 23
6. Terms of employment 26
6.1. Discrimination 26
6.2. Contracts of employment 28
6.3. Discipline 29
6.4. Worker representation 31
7. Health and Safety 33
8. Hygiene 39
9. Accommodation (living quarters) 41
10. Supply chain management 44
11. Environmental management 46
Appendices
1. Kingfisher Code of Conduct (updated July 2006) 49
2. Action Plan 53
Further documents and publications are available which support this book see page 11.
Version control
1.0 November 2006 Original guidelines issued
1.1 February 2013 Rebranded and reissued

1 Handbook for factories in India A guide to Kingfisher Standards for factory working conditions Version 1.1 February 2013
Introduction to the Kingfisher Group plc
Kingfisher is the third largest retail home improvement business in the world, with
market leading retail operating companies in the UK, France, Poland, Italy, China and
Taiwan. We have a vast supply chain stretching across the globe.
Kingfisher believes that, everyone involved in our supply chains should benefit from
trading with us (including subcontractors and home workers).
Kingfisher Social Responsibility Policy (May 2005)
Group companies
The Kingfisher Group consists of the following retail Operating Companies or ‘Op-Cos’ which sell home
improvement products, and operate several Overseas Sourcing Offices. Kingfisher has a 21% stake in
Hornbach, Germany’s leading DIY warehouse retailer.
Operating companies
Kingfisher’s operating companies are (as of November 2006):
B&Q (with over 320 stores in the UK and more than 50 stores internationally)
B&Q UK
B&Q Ireland
B&Q China
B&Q Taiwan
B&Q South Korea (first store now open)
Brico Dépôt
Brico Dépôt France
Brico Dépôt Spain
Castorama
Castorama France (with over 100 stores in France)
Castorama Italy
Castorama Poland
Castorama Russia (first store opened in 2006)
Koçtas
Screwfix Direct
Trade Depot
Overseas sourcing offices
Kingfisher also operates a number of direct sourcing offices including:
Kingfisher Asia Ltd (Hong Kong)
Kingfisher Asia Ltd (Shanghai)
Aricia (Sourcing in India for Kingfisher)
Kingfisher Sourcing (Eastern Europe)
Kingfisher Approvvigionamenti Italia (Milan)

What we expect
In order that everyone involved in our supply chains benefits from trading with us, all our products should
be made:
in safe and hygienic conditions
by workers who are properly paid and whose rights are respected
in factories which work to reduce their impact on local communities and the natural environmentt
This applies to all vendors, supplying any of the Operating Companies or Sourcing Offices, wherever they
are located. We recognise that some supply chains face more complex issues than others, but expect all
our vendors to be working towards continuous improvement in workplace standards.
We believe that high workplace standards, good health and safety, fair pay and employment conditions
and care for the environment are all elements of a successful, professionally run business. By working
together with our vendors to achieve these goals, we can strengthen all our businesses as well as
improving the quality of life of the people working in our manufacturing sites.
The Kingfisher approach is one of engagement with suppliers and workers, and recognises and respects
cultural diversity within supply chains. Our customers want new and exciting products at great prices, but
not at the expense of the people who make them. We are committed to sourcing products responsibly.
Kingfisher Social Responsibility Policy (May 2005)
factory working conditions
Our aim:
To ensure that everyone involved in our supply chains benefits from trading with us.
It is Kingfisher’s policy to:
know which supplier is making every product we sell and where these products are being made
set and assess workplace standards for our suppliers’ factories, including minimum standards which
must be met as a condition of supply and higher standards which suppliers are required to meet
within agreed timescales
work in partnership with our suppliers, governments and non-governmental organisations to address
challenging issues within our supply chains
provide help and guidance to those factories making our products in order to help them achieve the
required standards

Part 1
Part 1
Why are good factory conditions important?
Kingfisher believe that, everyone involved in our supply chains should benefit from
trading with us and we will work with our supply chain partners to deliver this goal.
Like many other retailers and businesses, we are being challenged to ensure that our products are made
in good working conditions and that the people working in our factories are being treated fairly. These
challenges are numerous and can come from various stakeholders; the media, campaigners, investment
companies, customers and our own employees.
Pressure groups often run public campaigns that focus on companies that are found to have poor labour
standards in their supply chains. These campaigns and other similar stories are reported in newspapers
and on the television. The news stories often concentrate on extreme examples of poor working
conditions, long hours and low wages.
These stories are seen by the people who shop and work in our stores. People do not want to buy
products that are made in poor working conditions because they do not want to be associated with or
encourage poor treatment of people. As a result retailers are finding that customers may choose not to
buy a certain product or shop at a certain retailer that has been mentioned in the media. Any potential
loss of sales will not only damage our business but will also reduce orders with our vendors.
The potential damage that poor working conditions can have on a business is also of concern to investors
who want to invest in companies that will continue to have strong sales. People who invest money in
companies like Kingfisher are asking questions about whether our business operates responsibly and
what we do to ensure that workers in our supply chains are treated fairly.
Our customers and our investors expect us to know where our products come from, and to take
responsibility for the working conditions in our supply chains. We need to maintain and build the trust
of these groups in order to protect and build our business. We want to sell products that our employees
are proud to sell and our customers are proud to buy. We can only do this if we can be confident that our
products are being made in good workplace conditions.

Part 1
The Challenges for Business
Globalisation
Globalisation has been defined by the World Bank as “the growing integration of economies and
societies around the world”.*
Globalisation has led to national borders becoming less visible and relevant, as trade between
large multi-national companies crosses those borders, and increases to the point where many large
companies have a turnover that is larger than the economies of many countries. Products from China
and Vietnam are offered to consumers in Europe and North America, and US branded sports goods
are offered for sale in South East Asia. There is a risk that the growth in this trade could lead to the
exploitation of cheap labour in some countries, and so the ILO is calling for “fair globalisation that
creates opportunities for all”.†
Kingfisher is therefore determined to work to increase the positive effects of global sourcing and reduce
potential negative impacts.
Examples of newspaper coverage: The Pioneer (Delhi), The Hindu and Business India
* Source: www.worldbank.org
† A Fair Globalisation: The role of the ILO. 92nd Session 2004

Part 1
International organisations
The International Labour Organisation is the UN specialised agency which seeks the promotion of social
justice and internationally recognised human and labour rights.
The ILO formulates international labour standards in the form of Conventions and Recommendations
setting minimum standards of basic labour rights; freedom of association, the right to organise, collective
bargaining, abolition of forced labour, equality of opportunity and treatment, and other standards
regulating conditions across the entire spectrum of work related issues.
Kingfisher fully support the aims of the ILO and has used ILO convention to form our response to the
working conditions issues we face in our supply chains. You will see the ILO reference where it has been
used throughout this book.
National governments
Different national governments place different legislative obligations on the businesses that operate
within their borders, and these laws can be well policed, or routinely ignored, according to local custom
and practice.
It is essential that all factories are aware of the laws that apply to them in the country in which they
operate, and that they abide by all such laws. In India for example we expect that all factories will
conform, where applicable, to the Indian Factories Act 1948.
Workers
Workers are becoming more aware of their legal rights and will increasingly put pressure on their
employers when they believe their rights are being withheld. Positive dialogue with your workers, through
committees, unions or associations will prevent the sort of unrest that will put your business at risk, and
can lead to improvements in productivity.

Part 1
Factories – What’s in it for you?
Kingfisher has been trading with factories all over the
world for many years – both directly and indirectly.
Over this time we have worked with all our trading
partners to better understand the countries, their
people, cultures and traditional working practices.
People from Kingfisher’s operating companies and
sourcing office visit our many factories, building
partnerships that we hope will be mutually beneficial.
We believe that high workplace standards, good
health and safety, fair pay and conditions, and care
for the environment can help you to strengthen your
business and to compete effectively in the global
market. Managing these standards can cut costs,
improve the productivity and therefore improve the
profitability of your company. It will also help you to
meet your customers’ needs and reduce your risks.
How can we work together to benefit your factory?
Increasing productivity
Safe and healthy workers make better products
Workers who are healthy, happy and safe work faster and produce better quality than those who are tired,
sick or stressed.
Continuous production
Fewer accidents and illnesses mean less downtime (time in which workers are unable to work). Downtime
can reduce productivity and increase the time it takes to complete orders.
Reducing risk
Fire
Fires can cause serious injury and death. A fire will result in expensive building repairs and may even
mean the closure of your factory. A few simple and inexpensive precautions will help to protect both your
workers and your business.
Accidents and injury
Accidents, injuries and illness may cause some workers to have periods of time when they are not able
to work. This is known as ‘downtime’ and may disrupt your production. Improving health and safety
conditions will reduce the number of accidents, injuries and illnesses that occur.
Reduced sales
Consumers may choose to stop buying from retailers who are associated with poor labour standards.
This can mean reduced sales for us which may then affect your business as it can result in orders
being cancelled.

Part 1
Managing costs
Wastage
Good working conditions generally mean good product quality. Better production quality can result in
less wastage.
Maintenance
A dirty workplace is not only a risk to the health of workers, it can also lead to extra costs for cleaning
to ensure that goods are not soiled and machinery does not break down.
Worker retention
Safe and hygienic factories attract the best workers and encourage them to stay. This reduces
training and recruitment costs. Ask yourself – how much does it cost you to train a new worker?
Improving your ability to meet your customers’ needs
Quality and productivity
Customers want consistently high quality products that are delivered on time and in full. Excessive
overtime has been shown to reduce employees’ productivity and the quality of products produced.
Customer confidence
Recognising customer needs by improving working conditions helps build a relationship of trust. The
improvements themselves will help you meet orders more effectively through better productivity and
quality, further strengthening your relationship with your customer, and improve your competitiveness.
How could your factory benefit from improved working conditions?

Part 2
Part 2
Kingfisher’s standards
What do we mean by working conditions?
The term ‘working conditions’ generally refers to the conditions you operate in your factory, for your
workers – for which we have set certain standards, covering the following issues:
age of workers
forced labour
hours of work
wages
discrimination
discipline
worker representation
health and safety
hygiene, accommodation and welfare
supply chain management
environment
Kingfisher’s Code of Conduct
Kingfisher has developed the ‘Kingfisher Code of Conduct for factory working conditions’ which has
recently been updated (see Appendix 1, page 49).
This Code of Conduct defines the labour and basic environmental standards that vendors supplying
Kingfisher operating companies must achieve in their factories* and worksites in our joint supply chains.
Kingfisher recognises the international standards set out in the International Labour Organisation (ILO)
Conventions†
. This Code is based on these standards and is designed to ensure that the rights of all
workers (whether permanent, temporary, casual or seasonal, local or migrant workers) are respected
and protected.
All vendors must be committed to:
giving Kingfisher visibility of its shared supply chain
complying with Critical Failure Points on all factories
working towards meeting these Kingfisher standards in their factories.
We recognise that not all factories will be able to achieve all of the standards immediately. However, all
factories must meet the nine Critical Failure Points (set out in following section), which define the minimum
entry standard for all vendors as a condition of supply.
The Critical Failure Points
Kingfisher will only buy from factories and worksites that demonstrate the following minimum
requirements:
1. The factory only employs workers who are over the local legal minimum age. Where this is less than
15, or where there is no legal minimum age, workers should not be less than 15 years old.§
2. Factories do not use forced, bonded or involuntary labour.
3. Workers are not forced to lodge unreasonable deposits or their identity papers with their employers.

Part 2
4. Workers are not subject to physical abuse, the threat of physical abuse, verbal abuse or any other
forms of intimidation.
5. There must be an adequate number of safe, unblocked fire exits, escape routes and fire fighting
equipment accessible to workers from each floor or area of the factory and accommodation (if
provided).
6. The factory is a safe and hygienic place to work.
7. Accommodation, if provided, is safe and hygienic, and is segregated from the factory or production
area and from material storage areas.
8. The factory does not knowingly contravene local and national environmental legislation without being
able to demonstrate a plan of action to improve.
9. Factory management demonstrates a willingness to improve on any significant areas of concern
identified and is committed to working towards meeting the standards of the Code of Conduct.
This handbook for factories is designed to help you as one of our factory managers, wherever you are
in the world, understand what the ‘Kingfisher Code of Conduct for factory working conditions’ means for
your factory and to help you to decide what action you need to take to make the required improvements.
This will enable us to work together to make progress in achieving our standards in all our mutual factories
and sites.
* The Kingfisher Code of Conduct for factory working conditions applies to factories and other forms of work or production sites producing
products to supply a Kingfisher Operating Company or Sourcing Office.
† The Kingfisher Code of Conduct reflects the standards set out in ILO Conventions, including the following:
ILO Core Conventions 29 and 105 and Recommendation 35 (Forced and Bonded Labour); ILO Core Convention 111 and Recommendation
111 (Discrimination in Employment and Occupation); ILO Core Convention 138 and Recommendation 146 (Minimum Age); ILO Convention
155 and Recommendation 164 (Occupational Safety & Health); ILO Convention 87, 98 (Freedom of Association and Collective Bargaining).
§ Factories should keep accurate records of the ages of all workers and should keep a list of young workers (under 18).

Part 3
Part 3
How to use this handbook
Your performance and progress will be monitored through periodic assessments by
one of the Operating Companies, or Overseas Sourcing Offices.
It is important for you to understand what meeting the Kingfisher standards means for all of your
production units and then to agree an action plan that will help you to make any necessary improvements.
This handbook will also help to explain the actions you need to take and the documents and records that
you need to maintain to demonstrate your performance and the improvements you have made.
This section of the handbook explains why good working conditions are important for Kingfisher operating
companies and why these issues are also important for you.
Part 4 of the handbook is divided into different issue areas which correspond to the issues covered in the
Kingfisher Code. It sets out practical guidelines to help you to identify where you need to improve and
suggests appropriate actions. It also includes a space for notes so that you can write down the current
situation in your factory and any actions you need to take.
In each issue area this handbook explains:
What’s the issue? – background information
What this means for your factory – advice and guidance, on how to meet the different standards, and
some recommended actions as to what you might need to do in your factory.
We suggest that you
Walk around the factory and talk to your managers, bearing in mind the points below. Where you find that
you need to make improvements, think about the specific action that needs to be taken and agree the
appropriate corrective action and timeline with your management team. You may wish to use the ‘Action
plan’ (see Appendix 2, page 53) to record this.
The section on ‘What this means for your factory’ may be split into three stages to encourage a stepped
approach towards continuous improvement. We acknowledge that these are complex issues which may
take time and energy to resolve and move forward, but we are committed to working in partnership with
you and our vendors on this, over time.
Starting out…
Here we have outlined the place to start on each issue, with Recommended actions on how to meet
Kingfisher Standards. Many of the standards included in this section are Critical Failure Points which
means you have to meet these standards, before you can supply Kingfisher.
Moving on…
Once you are supplying to us you should work towards these standards to develop and improve working
conditions in your factory.
Best practice…
In our best factories these practices are in place and we have learned from experience that these are
good practices which will help you run your factory well.
Recommended actions are those actions which in our view would ensure that you meet this level of the
standard.

Part 3
Reference information and support
To support and assist you we have also published:
Kingfisher Guide to India: Workplace Law and Regulations
These contain country specific, laws and regulations governing worksites, which we have compiled to
further inform our work in those countries.
Also we have available short Kingfisher fact sheets on different specific topics:
1. Chemical usage
2. Chemical storage
3. China: Health and Safety committee
4. China: Accommodation
5. Fire fighting
6. India: Supply chain management
7. Hygiene
8. Deposits
9. Child labour
10. India: First Aid boxes
All are available on www.kingfisher.com

Part 4
Part 4
What Kingfisher want to see in your factory
This section sets out how you can make practical improvements in your factory, in each issue area.
1. Management attitude and co-operation
1.1. What’s the issue?
Kingfisher only want to buy products from factories that are prepared to work with us and who are willing to
make improvements in areas where problems are identified.
1.2. What this means for your factory
Starting out…
To supply to us you need to meet the following standard
The factory management must demonstrate a willingness to improve on any significant areas of
concern.
Recommended action
You need to show us that you are prepared to work with us to make any improvements we feel are
necessary to ensure your factory meets our standards. This may take some time but if you are showing
willingness to improve and making gradual progress we will be happy to trade with you.
This handbook will help you to demonstrate this and will help you to achieve improvements.
Management attitude and co-operation notes
What is the situation in your factory?
What improvements do you need to make?

Part 4
2. Age of workers
Kingfisher believe that children should have the opportunity to grow up in a healthy and safe environment
with the opportunity for an education.
However, for one reason or another, children are sometimes involved in the manufacture of products.
If you find or suspect children are working in any of your worksites, the interests of the child must be
considered first and so it is vital that the child is NOT summarily dismissed. We will work with the vendor
or factory to agree an appropriate course of action that protects the child. If you find children either in
your workplace or in the factory of a vendor or sub-contractor please contact the operating company
that purchases your products immediately. We do not expect factories to take any action regarding child
workers without discussing it with us first.
Kingfisher believe that “child” means anyone under fifteen years of age, unless national or local law
stipulates a higher mandatory school leaving or minimum working age, in which case the higher age shall
apply; and “child labour” means any work by a child or young person, unless it is considered acceptable
under the ILO Minimum Age Convention 1973 (C138) Article 4:
“…a Member whose economy and educational facilities are insufficiently developed may, after
consultation with the organisations of employers and workers concerned, where such exist, initially
specify a minimum age of 14 years.”
Additionally young workers between the ages of 15-18 are in most countries given additional protection
in the form of work that they can and cannot do. For example most countries prohibit these young people
from doing any work that is deemed to be hazardous to their health – and often additionally restrict their
working hours and prevent night time working.
Reference: ILO Conventions 138 and 182, Recommendation 146 (Minimum Age), Recommendation 190
(Worst Forms of Child Labour)
Note: India have not ratified ILO Convention 138, but factories supplying Kingfisher should comply with
the standards laid down in the Kingfisher Code of Conduct.
Young workers

Part 4
Starting out…
All workers must be over the minimum legal age in the country in which you are operating. In any event
however Kingfisher believe that no young person under 15 should be working in their supply chain.
Recommended actions
You need to be able to demonstrate that all workers are over this age. This will include keeping
accurate records showing the age of each worker, with copies of identity papers showing their dates
of birth. It is important to ensure that you return the original identity papers to the workers. For example
in India a Ration Card, School Leaving Certificate, Voters Identity Card, Certificate from Certifying
surgeon or Dentists Certificate would be appropriate.
You will need to check these documents carefully to make sure they are genuine.
If you have workers who are under the age of 15, you must contact us to agree a course of action
which puts the welfare of any working children first. This is extremely important since simply
dismissing the child worker may worsen their personal position.
You must have a clear recruitment policy that ensures no recruitment of workers under the age of 15.
Moving on…
Once you are supplying to us you should work towards the following standards to develop and improve
working conditions in your factory
Young people below the age of 18 must not work at night (between 10pm and 6am).
Young people should not be working longer hours than those permitted by law.
Young people under the age of 18 should not work on tasks that are potentially hazardous to
health. This includes working with potentially dangerous machinery, hazardous chemicals or heavy
equipment.
Recommended actions
You should keep a list of workers under the age of 18. Records for these young workers should include
their working hours, duties and shift rosters to verify that you are complying with the above standards.
Notice on
factory gate

Part 4
Best practice…
In our best factories the following practices are also in place
If child labour is an issue in your factory, your must work towards participating in programmes that
help to eliminate child labour. This may mean working with local organisations or charities that have
developed programmes to help and support children removed from dangerous working situations.
Kingfisher is happy to work with vendors on specific project development work; please talk to your
contact at Kingfisher to discuss any such proposal.
Age of workers notes

Part 4
3. Forced labour
Forced or bonded labour occurs when someone does not have a choice about whether they work, what
work they do and/or when they work. Forced labour includes situations where factories retain workers’
passports, identity cards or residential permits, take deposits, withhold pay, or prevent workers from
leaving the site.
The following are examples that may be viewed as forms of forced labour:
Factories that take deposits from workers (e.g. to pay for tools, uniform or identity badges) which can
be difficult for the workers to get refunded.
Sites – often mines or quarries – that make workers pay for the tools they need and deduct a high cost
from their wages, but the debt is never cleared.
Factories who pay very low wages but offer very high interest rate loans – and deduct the repayment
from the wages – and so the debt is never cleared.
Paying workers two or more months in arrears. If workers leave they will be unlikely to receive the
money they are owed. Therefore they may have to stay at the factory even if they want to leave,
because they cannot afford to lose the deposit or other sums owed to them.
Compulsory overtime, where there is no system for workers to opt out of additional working hours, can
also be seen as a form of forced labour.
Products or components made by involuntary labour in prison camps, where the conditions are often
extremely poor. It is important that absolutely no part of the product or its components is made in
these conditions.
Reference: ILO Conventions 29 and 105, Recommendation 35 (Forced and Bonded Labour)
Human Rights Watch’s study of bonded child labour in India’s silk industry found that children typically
work between 10 and 14 hours a day, for six or more days a week. These children suffer from work
related injuries and illness and may also be subjected to abuse from their employers.
Starting out…
To supply to us you need to meet the following standards
The factory does not use forced, bonded or involuntary labour.
Workers are not forced to lodge unreasonable deposits or their identity papers with their employers.
Recommended actions
All workers have an employment contract, of which they have a copy clearly stating their hours of work,
and requirements regarding overtime and notice periods.
Workers must be free to leave the factory at the end of their shift.
You must ensure that none of the products, components or raw materials are made by forced prison
labour.
You must not take any deposits from workers, and if you are holding deposits they must be
immediately refunded.
You should not require your workers to leave their original identity papers or residency permit with
you. If you need to take copies of their identity papers you must return the originals to the workers and
ensure that they have somewhere safe to keep them. (If these documents are held for safekeeping
there must be a system for the workers to freely obtain their papers).
Workers should never be subjected to physical abuse, the threat of physical abuse or intimidating
verbal abuse.

Part 4
Moving on…
Any loan or credit schemes operated by factories for their workers should be transparent, clearly
explained to workers and fully documented.
Recommended actions
If you have any loan or credit schemes to lend money to workers, these should be clearly explained to
workers, voluntary and fully documented. Keep a copy in the personnel files.
Forced labour notes

Part 4
4. Hours of work
Workers in many factories around the world routinely work extremely long hours, often 10 or 12 hours per
day. Some workers have no choice about whether they work overtime or not and frequently do not receive
a premium for overtime. Many workers work 6 or 7 days a week and in busy periods may work for a month
or more without a day off.
This is a problem for a number of reasons:
Many countries do have laws restricting the maximum working week. This can vary from 35 to 48
hours but is rarely more than that. Your factory must be conforming to the laws of the land in which you
are operating. (In India see Factories Act 1948 & Shops and Establishments Act).
There may also be national guidelines on overtime and time off, which again you must know and
comply with.
All overtime should be voluntary or it could be seen as unacceptable ‘forced labour’.
Workers who work long hours become very tired and are more likely to have accidents or to fall ill. This
is damaging to their health and undermines their ability to work effectively and productively. These
workers may also sue the factory in court for compensation.
Kingfisher, in common with many other retailers, believe that people should not be made to work
excessive hours on a regular basis as it is potentially damaging to their health and well being.
India Factories Act 1948
U/s 51. Weekly Hours
No adult workers shall be required or allowed to work in a factory for more than forty-eight hours in
any week.
U/s 54. Daily Hours
Subject to the provisions of section 51, no adult worker shall be required or allowed to work in a
factory for more than nine hours in any day:
Provided that, subject to the previous approval of the Chief inspector, the daily maximum hours
specified in this section may be exceeded in order to facilitate the change of shifts.
U/s 59. Extra Wages for Overtime
(1) Where a worker works in a factory for more than nine hours in any day or for more than forty-eight
hours in any week, he shall, in respect of overtime work, be entitled to wages at the rate of twice his
ordinary rate of wages.
U/s 64. Power to make Exempting Rules
U/s 64 (4) (iii) the total number of hours of work in a week, including overtime shall not exceed sixty;
U/s 64 (4) (iv) the total number of hours of overtime shall not exceed fifty for any one quarter.
Explanation: “Quarter” means a period of three consecutive months beginning on the 1st of January,
the 1st of April, the 1st of July or the 1st of October.
U/s 65. Power to make Exempting Orders
U/s 65 (3) (i) the total number of hours of work in any day shall not exceed twelve;
U/s 65 (3) (ii) the spread over, inclusive of intervals for rest, shall not exceed thirteen hours in
any one day;
U/s 65 (3) (iii) the total number of hours of work in any week, including overtime, shall not
exceed sixty;
U/s 65 (3) (iv) no worker shall be allowed to work overtime, for more than seven days at a stretch and
the total number of hours of overtime work in any quarter shall not exceed seventy-five.

Part 4
4.1.1. What’s driving excessive working hours?
Overtime is a complex problem and there is no one single cause. The following factors all contribute to
long overtime working:
problems/delays with raw materials
tight lead times, poor forecasting – this may be a result of the buying policies of retailers
low-skilled workers
lack of communication between managers, supervisors and workers
high worker turnover.
Excessive overtime can result in:
low productivity
poor quality
high levels of reworking
poor health and safety (tiredness, illness, accidents)
high worker turnover
problems with recruiting new skilled workers.
All of these make it difficult for factories to work efficiently, to comply with the law and to meet the
expectations of their customers. It is factories which take small gradual steps that are most likely to
succeed in reducing overtime consistently.
Reducing the need for overtime
Because there are so many factors that contribute to excessive working hours, there is no simple way
to solve the problem. You will need to look at all of these factors to understand what is driving overtime
in your factory and to identify what you can do to improve the situation. Rather than just cutting working
hours, you need to think about ways of reducing the need for excessive overtime. If you can reduce the
need, then it will be possible for you to gradually reduce overtime.
Simply cutting working hours, without looking at all these other factors, may cause you serious problems,
as workers will leave the factory if their hours are cut without any opportunity to earn more in the hours
that they do work. There are often stories in the media covering incidents where workers have gone on
strike or caused unrest in response to sudden reductions in overtime, since their wages have dropped
abruptly as a result.
You need to find ways of reducing overtime which also take into account the needs of workers. This is
essential as you need their understanding and co-operation. Actions may involve:
improving productivity, so that workers can make more products and earn more money in a
shorter time
linking productivity and pay, so that workers have an incentive to work more efficiently
improving communication between workers, supervisors and managers – this is crucial. If people
don’t understand what is going on, it is hard for them to implement and support changes.
Some practical ideas on how to move forward
1. Measure the problem
Make sure that you are keeping accurate records of working hours.
These should show normal working hours, and all overtime hours, rest days and days taken as leave
for all types of workers on your site.

Part 4
2. Understand the problem
Look at the records, talk to managers, supervisors and workers to get everyone’s point of view and
ask the following questions:
Where is the overtime happening? Are there particular departments or sections where workers
work longer hours than others? Are there obvious bottlenecks?
When is the overtime happening? Does it happen regularly, or only occasionally?
What do managers and supervisors think are the factors causing overtime?
3. Take practical steps to reduce the need for long overtime hours
Focus on the areas and the times when overtime is a particular problem. Hold a meeting with managers
and supervisors to discuss what are the factors driving overtime in this area and what you might be able
to do about them.
Some ideas
If the problem is to do with: You need to focus on:
Inefficient production Improving production efficiency
This might include:
introducing straight line production (if possible)
defining standard critical paths and line layouts to maximise
efficiency
improving production planning
recording daily targets and hourly output levels on noticeboards
near the production line so that workers can see how they are doing
introducing bonuses to reward productivity
holding regular meetings with line supervisors to discuss problems
High levels of reworking Improving quality
This might include:
recording information about quality problems on noticeboards near
the production line so that workers can see them
hanging samples on or near the production line, so that supervisors
and workers can check what’s needed
for new orders: trialling a small batch of product through the
production process to identify problems at an early stage
training QC staff to spot problems
strengthening in-line quality checks
returning re-working as far as possible to the worker who made the
mistake so that lessons can be learned
Late delivery of raw
materials or poor quality
Working with your suppliers to ensure they are meeting your needs
This may include:
clearly communicating your expectations in terms of quality,
reliability and delivery
measuring their performance

Part 4
If the problem is to do with: You need to focus on:
Low-skilled workers Improving recruitment procedures to make sure you are hiring the
best workers
This may include:
drawing up a job description setting out the skills and experience
needed for each job
testing new workers to see if they have the skills you need and to
identify training needs
providing skills training for workers
High worker turnover Identifying ways to meet workers’ needs
This may include:
talking to workers who are leaving to understand why they no longer
want to work at the factory
talking with workers to find out what would make them want to stay
longer at the factory
holding management meetings to work out what you can do to better
meet their needs
Practical examples
You may find that there are some areas where relatively small and easy steps can be taken to make
improvements, streamline the production process and reduce the need for excessive overtime.
Hiring a small number of additional workers
Investing in more machines
Working to improve supplier performance
Improving communication
Rewarding workers for being more productive
We know that excessive working hours pose a serious challenge for many factories. Kingfisher accept
there is no easy and quick solution to this problem and instead expects its suppliers to be transparent
with us about the challenges that they face and work with us towards reducing working hours.
Moving on…
Standard working hours comply with the limit set by local law.
All overtime is voluntary and is paid at an appropriate rate.
Workers have at least one day off in every seven days as an average throughout the year.
Workers take suitable and sufficient breaks during the working day.

Part 4
Recommended actions
The factory must keep accurate records of workers’ hours of work. These records should cover all
groups/types of workers.
Normal contractual working hours (excluding breaks and overtime) should be less than or equal to
the legal maximum.
Workers should have a choice about whether they work overtime or not.
Hours of work notes

Part 4
5. Wages
Wages and costs of living vary hugely around the world, and low wages are often an issue that drives
the anti globalisation debate.
It is important to Kingfisher that all workers in our supply chains are paid at the legal minimum for the
country of operation, or at local benchmarks.
Wage calculations can be extremely complicated, making it difficult for workers to understand how
their wages are calculated. This confusion about wage calculation is made worse by the fact that many
people are not given a payslip or that payslips do not include enough information.
Factories now have to compete with each other to attract and keep the best skilled workers. Paying fair
wages will help you to do this. We believe that everyone should be paid a fair wage for the work they do,
in line with local and national wage legislation.
Reference: ILO Convention 131 and 90
Some practical ideas on how to move forward
1. Measure the problem
Make sure you know what the local minimum wage is and keep up to date with changes.
Keep accurate records of wages and hours worked, so that you know whether all your workers are
making minimum wage for standard time.
2. Understand the problem
Look at the records, talk to managers, supervisors and workers to get everyone’s point of view and
ask the following questions:
Which workers, in which departments, are not making minimum wage?
Pay particular attention to new workers, low-skilled workers or piece rate workers.
Are there particular departments or sections where workers make lower wages than others?
Does this happen regularly? or only occasionally?
3. Take practical steps to increase wages for low paid workers
Focus on the departments where low wages are a particular problem. Hold a meeting with
managers and supervisors to discuss what factors are driving low wages in this area and to agree
possible solutions. For example:
Do you need to recalculate piece rates so that workers can achieve minimum wage in standard
hours?
Do unskilled workers need more training to help them achieve minimum wage?
Do you need to pay probationary workers a temporary top up fee whilst they learn the skills
required?
Moving on…
Once you are supplying to us you should work towards the following standards
Wages and benefits comply with local law (or are in line with industry norms, where these are
higher than the legal minimum wage).
Any deductions from wages are clearly communicated to workers and are reasonable in the
context of the total wage.
Wages are paid regularly (at least monthly) and on time.
All workers receive payslips that clearly show how wages are calculated and all deductions
from wages.

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Recommended actions
Look at your pay records and talk to pay clerks and managers, bearing in mind the points below. Where
you find that you need to make improvements, think about the specific action that needs to be taken and
agree who will be responsible for taking the action and when they will do it by. You may wish to use the
‘Action plan’ in Appendix 2 to record this.
Deductions
You need to make sure that all workers clearly understand any deductions you make from their
wages.
Company policy on deductions and fines should be communicated to workers from the start of their
employment. Deductions and fines should be included in the factory rules or displayed on notice
boards. Deductions should also be noted on payslips given to workers.
All deductions must be reasonable in the context of the total wage. This is to ensure that after
deductions, workers have enough money left to maintain a safe and healthy lifestyle.
Wages
You must be able to demonstrate that all workers are receiving at least the local minimum wage
applicable to your factory for working standard hours.
To do this, you need to keep accurate pay and hours records. Including keeping careful records of
shift rosters and pay calculations.
Workers paid by the piece should be paid no less than the minimum wage based on a reasonable
quota.
Minimum wage should not include any non-currency benefits such as the employer providing meals,
dormitories, etc.
Payment
Wages should be paid regularly (at least monthly) and on time.
Workers’ wages should be paid in cash or paid directly into their bank account.
Workers should receive pay slips showing hours worked (both standard hours and overtime hours);
the rates of pay, any deductions made from their pay and the benefits that they receive, these payslips
should be easy for workers to understand.
Are you paying
the correct
amount for
overtime?

Part 4
Benefits
You must ensure that you know what benefits your workers are entitled to by law and that all your
workers receive their full legal entitlement to these benefits.
These benefits may include:
social security pay
maternity leave and pay
insurance
paid leave
pension contributions
medical insurance
Best practice…
In our best factories the following practice is also in place
If wages paid in your industry are normally significantly above the minimum wage, you should work
towards paying workers in line with what is typical in your industry.
Wages notes
What is the situation with wages in your factory?
Sample of Indian wage slipAttendance register

Part 4
6. Terms of employment
This section covers a number of issues in the area of how workers are treated. This section includes:
6.1. Discrimination
6.2. Contracts of employment
6.3. Discipline
6.4. Worker representation
6.1. Discrimination
6.1.1. What’s the issue?
We believe that each person should be treated equally with the We believe that each person should be
treated equally with the same level of respect and receive the same level of benefits or privileges. We do
not expect to find discrimination in access to employment, training and working conditions, on grounds
of race, colour, sex, religion, political opinion, nationality or social origin. We expect factories to promote
equality of opportunity and treatment.
Groups of people who are particularly vulnerable to discrimination are:
Women
Young people
Migrant or immigrant workers
Subcontractors and workers in the informal sector
Temporary workers/workers on short-term contracts
Probationary workers
Workers in Special Economic Zones or similar
Workers who work in isolation (e.g. homeworkers)
People with disabilities
People belonging to Scheduled Castes, Scheduled Tribes or OBCs
Reference: ILO Conventions 100 and 111, Recommendations 90 and 111 (Equal Remuneration for male and
female workers for work of equal value; Discrimination in employment)
Are female
workers treated
equally?

Part 4
6.1.2. What this means for your factory
Moving on…
Once you are supplying to us you should work towards the
following standard
There is no discrimination in hiring, promotion or employment
conditions on any grounds.
Recommended actions
There should be no discrimination on any grounds in the
hiring of workers.
There should be no discrimination on any grounds in workers’
conditions of employment (including payment, benefits,
promotion opportunities, etc).
This means that the rights of all workers are honoured and
respected equally, irrespective of gender, religion, culture,
national and social origin, language, sexual orientation,
disability, political affiliation or union membership.
Women should not be made redundant or dismissed due
to pregnancy, should have their full entitlement of maternity
leave and benefits, and have the right to return to work.
Best practice…
The factory should have documented policies and procedures covering hiring and employment which
show that all workers are treated equally.
Employment contracts should demonstrate that workers are treated equally.
Pay and hours records should demonstrate that men and women are paid the same rates for doing the
same job.
Discrimination notes

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6.2. Contracts of employment
It is important that all workers are aware of the terms of their employment. This means having these
terms explained to them and also clearly set out in a contract, which they can keep a copy of. If workers
clearly understand their terms of employment including pay, hours, disciplinary procedures, they are
less likely to be misunderstandings and the workers are more likely to be content in their work. Factories
can use contracts and handbooks or employment guidelines to explain clearly what the conditions of
employment are.
All workers even temporary or contract workers employed for a fixed time – must be made aware of the
terms of their employment.
Starting out…
All workers have a copy of a written contract of employment that sets out the terms and conditions of
their employment in a language that they understand.
Those workers whom you employ on a temporary basis should also have a clear understanding of their
own terms and conditions or work – including length of contract, pay rate, etc.
Recommended actions
All workers must have written contracts. Even if these are also explained verbally a written document
will mean that both the person involved can refer to their terms of employment at any time, or ask
someone else to explain details of it.
A copy of the individual employment contract should be kept by both the worker and the factory
management.
Moving on…
Once you are supplying to us you should work towards the following standard
Workers should be provided with a written copy of any factory rules or regulations, in a language that
they understand. These rules should include details of disciplinary procedures, the process for opting
out of overtime, the process for requesting leave and the process for resignation.
Recommended actions
You must make sure that workers are aware of the terms of their employment. This means that their
full terms of employment (including pay, hours, benefits, grievance procedure, etc.) should be clearly
communicated in a language that is understood (written and spoken) by the employees.
This should involve a verbal briefing when workers are recruited but should also include providing all
workers with a written document showing their terms of employment including wages, standard and
overtime hours, and benefits including paid leave and grievance/discipline procedures.
Best practice…
Factories regularly review contracts to improve the terms and conditions of workers overtime. This will
mean that you retain your experienced skilled workers which will save you money in terms of training
and re-training, and improve productivity.

Part 4
Contracts of employment notes
What is the situation with contracts in your factory?
How many permanent and how many temporary workers do you have?
Length of time the average temporary workers has worked for you?
Are temporary workers appointed by you or through your contractors?
6.3. Discipline
It is extremely important that none of the workers in your factory are intimidated or abused in any way.
This is a Critical Failure Point for Kingfisher and meeting it is part of the minimum conditions to supply
Kingfisher companies. Any disciplinary practices should be fair and legal, and should be fully understood
by the people working in your factory.
Starting out…
Workers are not subject to physical abuse, the threat of physical abuse, verbal abuse or any other
Recommended actions
This means supervisors and managers should be trained in the factory’s disciplinary procedures and
should be monitored to ensure they are enforcing them fairly.
You need to monitor your factory for any signs of intimidation, bullying or abuse.
Moving on…
All disciplinary rules are written and communicated to workers in a language that they understand.
Recommended actions
Factory rules and disciplinary procedures that apply to the factory should be written down and posted
somewhere in the factory where they are easily accessible to all workers.
These rules and procedures must be clearly communicated to workers. This can be done by giving
workers a written copy of the factory rules and disciplinary procedures, in a language that they
understand. The rules and procedures should also be clearly explained verbally to new workers. A
written copy of the rules and procedures should also be given to each person so they can keep it for
reference.

Part 4
Deductions and fines
All wage deductions are clearly understood and reasonable in context of total wage (see page 23, Wages).
Record keeping
Breaches of the rules and subsequent disciplinary actions should be recorded in a central log. This means
that whenever a worker breaks the factory rules this should be recorded by managers. If the managers take
disciplinary action against the worker this should also be recorded.
Best practice…
In our best factories the following practice is also in place
The factory has a performance related reward system for workers, which rewards workers for good
performance.
Discipline notes
Factory rules

Part 4
6.4. Worker representation
There needs to be a good flow of communication between workers and management, to allow workers’
views to be discussed with management and solutions to be found. Where there is good communication
within the factory, workers are more likely to work efficiently and stay at the factory longer.
Reference: ILO Conventions 87 and 98. Also relevant are Convention 135 and Recommendation 143 (Workers’
Representatives), and Convention 154 (Collective Bargaining)
Starting out…
Workers should have the right and freedom of choice to belong, or not to belong to a trade union of
their choosing, without pressure or influence from the business.
Where this right is restricted by law, management should facilitate the development of alternative
means for workers’ representation as permitted by the legal framework.
There is a clear, recognised process of worker representation to ensure good flow of communication
between workers and management and to allow workers’ views and opinions to be discussed with
management.
Workers representatives are not discriminated against and have access to carry out their
representative functions in the workplace.
Recommended actions
This means that factories should have a process which allows
workers to raise their concerns and encourages negotiation with
the management to find solutions.
We recommend that this involves an elected workers committee.
Regular meetings should be held with managers and workers’
representatives to discuss workplace related issues.
Records should be kept of the meetings, with details of what
was discussed and of the actions that were agreed. The
response of the management to the concerns raised should be
communicated to all workers using the notice board.
Do you have regular
meetings with your
workers?
Suggestion box

Part 4
Moving on…
Workers should have the right to bargain collectively, in unions or groupings of their choosing.
These meetings should allow for discussion of all workplace issues including pay, health and safety,
and other conditions.
Workers representatives should be chosen by the other workers to negotiate with managers.
A list of worker representatives should be kept.
Best practice…
A worker representative is elected on to the Main Board of the business to represent the views and
interests of the workers at this senior level.
Worker representation notes
What is the situation with worker representation in your factory?

Part 4
Case study
On a 2004 visit of a proposed factory, a
Kingfisher auditor found the factory to be a
totally unsatisfactory workplace, with major
health and safety risks. However a clear
action plan was agreed with the factory
manager, recording what needed to be
done before this factory could become a
trading partner of a Kingfisher company.
On a subsequent visit the factory had
been transformed into a safe working
environment. We spoke to the factory
manager and the workers. The factory
manager said that his workers were
now much happier and that quality and
productivity had improved. The workers
said they were happier as there were less
accidents and injuries, and they were now
more likely to stay at the factory, instead of
leaving to find work elsewhere.
7. Health and Safety
People should not have to work in an environment that is potentially dangerous or harmful to their health.
Factories with a safe and healthy working environment attract the best workers and encourage them
to stay. This reduces training and recruitment costs and improves productivity. Production can also be
disrupted by downtime, when workers are not able to work as a result of illness, injury and accidents. If
there is a fire in your factory this can cause serious injury and death, and will cause a loss in production
and may even lead to the closure of your business.
Key problems in factories tend to include:
Machinery and chemicals
Use of dangerous machinery, without guards and without personal protective equipment.
The use of chemicals in manufacturing processes also leads to high rates of illness. Workers can
suffer serious health effects and may even die if they are in a confined space and inhale large amounts
of hazardous chemicals including volatile solvents. Contact with solvents can cause skin irritation
and soreness; irritation to the eyes, nose, windpipe and lungs; light-headedness or drowsiness and
damage to the central nervous system. Prolonged exposure can cause permanent damage to liver
and kidneys and various sorts of cancer.
Excessive hours can increase workers’ exposure to hazardous chemicals, above safe levels.
Health and fire safety
Even when factories have first aid boxes, they can be poorly stocked or empty. Someone needs to be
trained in first aid, and the first aid boxes must be easily accessible to all.

Part 4
Fatalities in factories often occur as a result of fire. Factories might not have sufficient, maintained fire
fighting equipment or no one knows how to use it properly. Regular Fire drills are important although
these are frequently not executed and therefore workers do not know what they should do in a fire. Fire
escapes can be blocked or locked and windows barred, preventing workers from getting out of the
factory. Managers and workers often have little understanding about the safe handling of flammable
materials.
Personal protective equipment
Appropriate personal protective equipment (PPE) is not always provided in factories. Even when it
is distributed workers might be charged for it and it may not be maintained and repaired if broken.
When PPE is provided, many workers do not use it since they do not perceive themselves to be at risk.
Workers also may not use the PPE if it slows down their production and therefore reduces the amount
they can earn on piece rates.
Practical help in making improvements
How to carry out a Health and Safety Risk Assessment
To address the issues listed above, your factory should carry out regular health and safety risk
assessments.
This means that the health and safety manager looks at all the processes in the factory and all the
areas of the production site and identifies areas where workers could be harmed. This may include
blocked fire exits, use of hazardous chemicals, machines producing dust, unguarded machines, loud
machines, etc.
These potential risks should be written down.
For each risk identified, an action should be agreed to reduce or remove the risk. This may include
use of appropriate personal protective equipment, replacing a hazardous chemical with a less harmful
substance, providing ventilation in the factory, etc.
These actions should be written down. For each action, the manager should decide and record who is
responsible for carrying out the action and when they should do it.
The manager responsible for health and safety should check whether these actions have been
completed and record what has been done.
You can then use these records to show that health and safety improvements have been made
according to past action plans.
Fire exists should be clear
and unblocked

Part 4
Starting out…
There must be an adequate number of safe, unblocked fire exits and escape routes accessible to
workers from each floor or area of the factory and accommodation (if provided).
The factory is a safe place to work.
Recommended actions
Carry out a full health and safety risk assessment on your factory, to identify those areas where you
need to take action.
Fire extinguishers should be regularly checked (at least once every year) to ensure they are working
correctly. You should keep a record of these checks.
All fire escapes must be kept clear and unlocked.
Fire prevention and fire fighting equipment must be provided. This includes an adequate number of
fire extinguishers and hoses.
All fire exits are clearly marked in a language workers understand or shown graphically.
Regular fire drills should be held (at least once every six months), including fire drills during night
shifts. Records of fire drills should be kept, showing the time taken to evacuate the buildings.
There must be clear signs directing workers to the fire escapes. The fire exits should be clearly
marked. These signs should be in a language all workers understand or shown in picture form.
Adequate ventilation should be provided if dust is produced or if any chemicals are used that release
fumes or vapours.
You must provide basic first aid facilities, for example, a well stocked first aid box which is accessible
to all.
An accident book should be kept recording all accidents, the cause, and any remedial action taken to
prevent recurrence.
Have you got enough fire
extinguishers in the right places?
Are there clear signs directing
workers to fire escapes?

Part 4
The factory should develop an evacuation plan and communicate it clearly to workers. The evacuation
plan should also be displayed in the factory and in accommodation if provided.
Personal protective equipment should be issued where appropriate.
Adequate steps must be taken to prevent avoidable health and safety hazards.
Moving on…
The use of hazardous substances/activities is kept to a minimum. The risk of harm from hazardous
substances/activities is minimised through the provision of safety equipment, signage, training and a
safe factory infrastructure.
There is a specific, named manager with responsibility for health and safety.
Recommended actions
Fire safety
There must be a fire alarm system. The fire alarm should be tested regularly, but a minimum of every
six months.
For hygiene and fire safety purposes, the factory should restrict smoking to certain areas. No smoking
signs should be displayed in other areas where smoking is not permitted.
Personal protection equipment (PPE)
Appropriate personal protective equipment must be provided for all workers. This includes those
using potentially hazardous machines or handling chemicals.
The factory must ensure that the personal protective equipment provided and used is appropriate to
the task.
All personal protective equipment should be provided free of charge.
Training
The factory must ensure that workers are trained in the hazards associated with their jobs and why
personal protective equipment needs to be used.
All workers using machinery should be trained in the safe use of this machinery.
Workers should be given appropriate health and safety training on the safe handling, storage and
disposal of hazardous chemicals/materials. This training should also include how to use personal
protective equipment and how to clean up chemical spills.
Records of health and safety training should be kept.
When did you last hold a fire drill?

Part 4
All workers must be given fire safety training. This should include how to evacuate the building if a fire
occurs and also how to use fire extinguishers. Records of this training must be kept.
Designated workers must be appointed as fire officers to lead the evacuation from the workplace.
Machinery and chemical safety
Safety guards must be in place on all potentially hazardous machines.
The use of hazardous substances should be kept to a minimum.
Hazardous chemicals should be stored in a locked storage area, which is separate to the main
production unit.
Further information and practical guidance can be found in fact sheets 1, 2 and 3.
Housekeeping
You need to check that all aisles, corridors and spaces between machines are clean and clear of
waste and of products. The layout of machines, worktables and equipment must allow for people to
work safely and also to walk through the production area safely. This will also ensure that workers can
escape safely and easily if a fire occurs.
Electrical equipment and wires must be in good repair. This means they should be well insulated and
equipped with safety fuses. They should be regularly inspected and repaired by a qualified electrician.
First aid and health
First aid boxes must be easily accessible to workers in all production areas and must be stocked with
supplies that are appropriate for the production process.
Adequate medical facilities should be provided appropriate to the size of the factory. This might
include a medical room, or arrangements with a nearby hospital to allow treatment of workers in an
emergency.
Management of Health and Safety
The factory should have a clear understanding of the health
and safety hazards that are associated with working in the
factory. This includes knowing which machines and which
chemicals are potentially hazardous.
The factory must give responsibility for managing health and
safety to a named manager. That manager is responsible
for identifying health and safety risks and implementing
improvements to reduce or eliminate the risks.
Does this look safe to you?
What is in your first aid box?

Part 4
The factory should have a clear, written Health and Safety policy, which outlines the main health and
safety risks associated with the workplace and the processes carried out. The policy should also state
what actions are taken to reduce or eliminate the main risks and who is responsible for managing
health and safety. The Health and Safety policy should be displayed in the factory.
Best practice…
Factories are able to demonstrate proactive management and improvement of health and safety
issues.
Recommended actions
There should be a trained first-aider, nurse or doctor available, appropriate to the size of the
workforce.
The factory should work towards providing occupational health monitoring for workers.
Health and safety risk assessments should be carried out regularly.
Action plans should be in place leading to continuous improvement in this area.
The factory should be well-lit. The temperature should be kept at a comfortable level by heating
or cooling as appropriate. Ventilation and/or fans may be necessary if the factory tends to
become too hot.
Health and Safety notes
Are you using appropriate personal protective equipment?

Part 4
8. Hygiene
The factory must provide a clean and hygienic place of work and rest. This is important because:
a dirty workplace is a risk to the health of workers and can cause workers to be less productive
it can also mean extra cleaning and maintenance will be needed to ensure goods are not soiled and
machinery does not break down
an untidy workplace can make production less efficient and can cause obstructions for workers if
they need to leave the building quickly in an emergency
our customers want to buy products that are made by people who work in healthy and hygienic
work places
It is important that all areas of the factory are clean – this includes the production areas, storage areas,
kitchens, canteens, accommodation, toilets and washing facilities.
Moving on…
The factory provides a clean and hygienic place of work and rest consistent with local standards and
the nature of the industry.
Workers have access to clean and safe drinking water at all times.
Workers have access to sufficient clean and hygienic toilets and washing facilities.
Recommended actions
Toilets, washing facilities, kitchens and any food preparation facilities should be kept clean and
hygienic.
Shower facilities should be available for workers engaged in heavy or dirty manual labour. Workers
should have access to clean washing facilities at the beginning and end of each shift.
Are bathroom
facilities clean
and hygienic?

Part 4
There must be a supply of drinking water in each production area, available close to the workstations.
This drinking water must be clean and safe. Ideally there should be both cold and hot water. Workers
should have unrestricted access to this drinking water at all times.
Pests such as insects or rats are unhygienic and can spread illness. Factories arrange for regular
pest control assessments by pest control experts, where relevant. If a problem of pests is discovered
appropriate measures are taken to eliminate the pests.
On the production floor
The factory should be clean. There should be designated individuals to clean production areas.
The production areas and storage areas should be kept tidy – including keeping all passages
between machines clear of waste and products.
The factory should restrict eating and drinking to certain areas. Signs should be displayed in other
areas stating that there should be no eating or drinking. This is especially important where chemicals
are used or stored.
You need to ensure that the factory provides an appropriate number of flushable toilets (and washing
facilities) for the number of workers employed in the factory. Responsibility for maintaining hygiene
standards should be designated to an appropriate person.
Best practice…
Your factory should work towards being able to demonstrate that you are actively managing the issues
of health and hygiene and that you are making continuous improvements.
This means that you can show that you have identified the health and hygiene risks in your factory and
that you have produced appropriate action plans. You need to be able to show that past action plans
have been implemented and that improvements have been made.
Hygiene notes
Do workers have access to clean and
safe drinking water at all times?

Part 4
9. Accommodation (living quarters)
Many factories in different countries around the world do provide accommodation, or housing for factory
workers. This is often a good solution particularly for migrant workers. Many workers prefer to live in
factory accommodation since they are usually cheaper and more convenient than accommodation
outside.
This section refers to all accommodation arranged for workers, either through the factory or through
external private landlords. Accommodation varies from factory to factory, but our view is that if
accommodation is a part of the workplace these lodgings form part of the employees’ terms of
employment. If accommodation is outside the factory, but arranged or funded in any way by the factory
then the factory has a responsibility for ensuring that these place are safe and hygienic. No profit should
be made from this arrangement by the factory through charging high rents, or overfilling accommodation.
Workers have the right to live in safe, hygienic conditions with a degree of comfort relative to local
conditions. Your factory will attract and keep the best workers if living conditions are of a better standard
than other factories in the area. If workers are content with their living conditions and are able to rest well
they will work more productively.
See Kingfisher China: Accommodation fact sheet 4 for more help on this issue.
Starting out…
Accommodation is segregated from the factory or production area and from material storage areas.
Adequate provision is made for the fighting of fire and evacuation in accommodation areas.
Recommended actions
Accommodation buildings
Accommodation, if provided, must be in a separate building to production units and warehouse areas
for safety reasons.
Accommodation buildings must be safe.
Fire safety in accommodation buildings
There must be sufficient fire escape routes and fire exits for workers to evacuate each floor of the
dormitories safely in an emergency. We advise that there should be at least two fire exits from each
floor so that, if one exit is blocked by fire the workers can still escape.
All fire escapes must be kept clear and unblocked.
If the main dormitory doors are locked at night for security reasons, emergency exits must not be
locked and must be freely accessible from inside the building.
Moving on…
Accommodation is clean and hygienic, comfortable and provides for individual privacy.
Recreational facilities are provided within or accessible to the living area.
Recommended actions
All accommodation areas must be clean and hygienic at all times. There should be an organised
system for regular cleaning of these areas.
Each sleeping room should have sufficient space for each worker.

Part 4
Dormitories should be comfortable and should provide for the workers’ basic needs. This includes
providing a place to store their personal belongings safely and securely (e.g. personal locker).
Rooms should be light, well-ventilated and heated/cooled to counter extremes in temperature.
Separate sleeping areas should be provided for men and for women.
Basic recreational facilities should be provided.
Toilets and washing facilities
The number of toilets (and washing facilities) must be suitable for the number of workers.
Workers should have easy access to a sufficient number of flushable toilets and washing facilities.
All toilets and washing facilities and food preparation facilities must be clean and hygienic at all
times. There should be an organised system for regular cleaning of the accommodation, toilets,
washing facilities and food preparation areas.
Fire safety in accommodation areas
If there is a fire, people must be able to escape from the buildings safely and there must be sufficient
equipment to control the fire. To enable this to happen the factory needs to provide the following:
Fire prevention and fire fighting equipment must be provided. This includes an adequate number of
fire extinguishers and hoses. Fire extinguishers should be regularly checked (at least once every year)
to ensure they are working correctly. You should keep a record of these checks.
There must be clear signs directing workers to the fire escapes. The fire exits should be clearly
marked. These signs should be in a language all workers understand or shown in picture form.
There must be a fire alarm system. The fire alarm should be tested every six months.
Regular fire drills should be held in the accommodation areas (at least once every six months),
including fire drills at night. Records of fire drills should be kept, showing the time taken to evacuate
the accommodation.
The factory should develop an evacuation plan and communicate it clearly to workers. The
evacuation plan should also be displayed in the accommodation areas.
Designated workers must be appointed as fire officers to lead the evacuation from the
accommodation.
Accommodation must be at a safe distance from areas where flammable materials (e.g. foam,
chemicals, etc.) and other hazardous chemicals are used or stored.
Fire exits should
be clearly marked

Part 4
Best practice…
Each worker should have some level of personal privacy.
Married workers and families should be able to live together in separate accommodation.
Where possible workers should have access to comprehensive recreational facilities, free of charge
(such as a basketball court, gymnasium, library, pool tables or karaoke).
Accommodation (living quarters) notes
What is the situation with accommodation in your factory?

Part 4
10. Supply chain management
Global Supply Chains are long and complex and involve numerous subcontractors and component Global
Supply Chains are long and complex and involve numerous subcontractors and component suppliers
as well as raw material suppliers. These suppliers and subcontractors may be using different types of
factories and worksites, including home workers and informal working units.
Often the working conditions for workers are worse in these subcontracting units and component
suppliers. It is important that home workers and workers in small separate units are also provided with
good working conditions. Workers employed by your subcontractors should also have fair and safe
working conditions.
To be sure that all of the products you sell to us are made in good conditions, and to safeguard quality,
you need to have responsibility of your whole supply chain, including sites which carry out subcontracted
processes for you and also your component suppliers. You need to be managing any risks within your
supply chain. We are responsible for our supply chain from top to bottom, through our vendors and you
are a part of this chain.
Note: Kingfisher will require from all vendors and factories product level detail of what product is being
made on which site – and details of any subcontracting or component level work being done away from
the main site – as a condition for supplying Kingfisher.
Starting out…
Factory managers understand the supply chain of their products and are willing to provide details of
the supply chain to the relevant Kingfisher Operating Company/Sourcing Office.
Subcontractors and home workers are only used where there is full visibility of the entire supply chain.
Recommended actions
Knowledge of supply chain
You must keep an up-to-date list of any
subcontractors, home workers and key
component suppliers.
You need to know how workers are treated
at any subcontracting or home working
sites. This includes knowing what health
and safety measures are taken both in
the factory and accommodation, how
workers ages are recorded to ensure that
no-one under 15 is working on the site and
whether large deposits are held to prevent
workers from leaving. This will involve open
communication with your subcontractors
and home workers. If you are ensure about
what to look for in the first instance it is a
good idea to start by looking at the Critical
Failure Points for Kingfisher and ensuring
that these are being met.
We need to have visibility of the whole supply chain

Part 4
You need to know which sites supply you with component parts. You must be aware of any sites
carrying out subcontracted processes for you and any home workers who contribute to the
manufacture of your products.
Factory managers must be willing to share this information on the supply chain with us. This is
important since we need to know exactly where each product is manufactured.
Best practice…
Factory managers work with their key suppliers and subcontractors to help them work towards
meeting these standards over an agreed period of time.
Recommended actions
Visiting suppliers and subcontractors
This involves visiting and assessing key suppliers and subcontractors against Kingfisher standards,
if you believe there is likely to be a risk of environmental or ethical issues. You need to work with your
suppliers and subcontractors to encourage improvements on key issues.
You should keep records of these visits, listing any risks identified and any improvement actions that
are agreed. You need to contact or visit the suppliers and subcontractors to check that actions have
been done. You need to keep evidence of the improvements that have been made.
Action plans
You need to find out the key issues that exist in any subcontracting or home working units. This may
include poor health and safety, low wages or long hours. You need to agree with the subcontractors
or home workers how you will support them to make improvements and agree on specific action plans
that will ensure that workers are treated fairly.
Factory managers need to have a detailed understanding of all component and raw material suppliers
and subcontracting units.
Supply chain management notes
What is the situation with supply chain management for your factory?
What are the
health and safety
conditions in your
supply chain?

Part 4
11. Environmental management
Good environmental management ensures your factory is limiting its impact on the environment, both
locally and globally, and that it is operating sustainably. To successfully trade with Kingfisher companies,
factories need to be aware of, and take action on their environmental impacts.
For example disposal of potentially hazardous waste into the air, into water or onto land can result in health
problems for nearby populations and also damage to the global environment. Many governments set
limits on the emissions that can be released. Reducing emissions may involve actions such as treatment
of waste water or installing a filter for gas emissions. You may also need to consider more careful disposal
of hazardous chemicals used in production processes.
This section also covers the reduction of your use of certain chemicals that are restricted by regulations,
for environmental reasons. You should also be aware of any natural resources you use and consider how
you can make sure that they are sourced sustainably.
Kingfisher Social Responsibility Policy identifies Product Stewardship as a key issue, and aims: ‘To give
our customers confidence that the environmental and social issues associated with the products they buy
from us are properly managed’ (see Kingfisher Social Responsibility Policy). You will therefore need to be
aware of all Kingfisher Product policies and be able to work with us, on them.
Environmental management means being aware of all the possible impacts that your production site might
have on the environment and deciding how you can minimise these impacts.
Practical help on making improvements
Developing an environmental policy
A meaningful environmental policy is one which:
identifies the main environmental impacts of the business
sets out a basic management system, including assessing environmental impacts, setting targets for
improvement and reviewing progress on a regular basis
defines responsibilities: the policy should outline the role of employees and include the name of the
senior manager with ultimate responsibility for environmental performance
The policy should be signed by the Chief Executive or the most senior Company Officer.
Ultimately, the environmental policy should give confidence that the company is aware of its impact on the
environment and is committed to doing something about it.
Starting out…
The factory does not knowingly contravene local and national environmental legislation without being
able to demonstrate a plan of action to improve.
The factory operates as per the norms laid down by the local Pollution Control Board.
Recommended actions
Complying with environmental legislation
You must be familiar with any environmental legislation which affects your factory.
You must be able to demonstrate compliance with any relevant legislation e.g. by having up-to-date
certificates to show that the factory meets the legal requirements. This may include regulations on air
emissions, solid waste disposal and liquid waste disposal.

Part 4
If you do not meet environmental legislation, you must have a plan of action that commits your factory
to making improvements in order to meet the requirements.
You must know what impacts your factory has on the environment. This includes knowing what gases
are released and what solid and liquid waste is released. You should also have records of any waste
treatment.
Moving on…
The factory understands its environmental impacts, complies with local and national environmental
legislation, or is able to demonstrate a plan of action to improve.
Factories have a meaningful environmental policy signed by the Chief Executive or the most senior
Company Officer.
Where necessary, factories should have an environmental action plan against which progress is
measured.
Recommended actions
You should have a list/register of the environmental impacts of your operations.
You should have a system for keeping all appropriate environmental documentation e.g. waste removal
and pollution control licences and movement sheets.
You should have an environmental policy, signed by the Chief Executive or the most senior Officer of
the Company of the factory.
How safe is your
chemical store?

Part 4
Best practice…
Developing a thorough environmental management strategy
You must develop an action plan which shows how the environmental impacts of your factory are
being minimised. You should record progress on this action plan and be able to use it to demonstrate
measurable reductions in environmental impacts over time.
You need to be able to demonstrate that the factory has operated for the past three years without
prosecution under Environmental Legislation.
Environmental management notes
What is the situation with environmental management in your factory?

Appendix
Appendix 1
Kingfisher Code of Conduct for factory working conditions
July 2006
First edition published June 2005
Introduction
This Code of Conduct defines the labour and basic environmental standards that vendors supplying
Kingfisher operating companies must achieve in their factories 1
and worksites in our joint supply chains.
Kingfisher recognises the international standards set out in the International Labour Organisation (ILO)
Conventions. 2
This Code is based on these standards and is designed to ensure that the rights of all
workers (whether permanent, temporary, casual or seasonal, local or migrant workers) are respected and
protected.
All vendors must be committed to:
giving Kingfisher visibility of its joint supply chain
complying with Critical Failure Points on all factories
working towards meeting these Kingfisher standards in their factories.
We recognise that not all factories will be able to achieve all of the standards immediately. However,
all factories must meet the nine Critical Failure Points (set out on the following page), which define the
minimum entry standard for all vendors as a condition of supply.
Implementation
Each Operating Company and Sourcing Office is required to develop a strategy and action plan for
supporting continuous improvement in vendor performance with the ultimate goal of bringing all vendors
and their supply chains into line with the entire Code. Progress towards achieving this is monitored
through the ‘Steps to Responsible Growth’ management system.
Strategies must include:
a commitment to obtain transparency throughout the supply chain
specific targets for the vendor base and supply chain
clearly defined requirements
systems for assessing performance
systems for following up non-compliances
responsibilities
resourcing.
Critical Failure Points
Kingfisher will only buy from factories and worksites that demonstrate the following minimum
requirements:
1. The factory only employs workers who are over the local legal minimum age. Where this is less than
15, or where there is no legal minimum age, workers should not be less than 15 years old. 3
2. Factories do not use forced, bonded or involuntary labour.
3. Workers are not forced to lodge unreasonable deposits or their identity papers with their employers.
4. Workers are not subject to physical abuse, the threat of physical abuse, verbal abuse or any other
5. There must be an adequate number of safe, unblocked fire exits, escape routes and fire fighting
equipment accessible to workers from each floor or area of the factory and accommodation (if
provided).

Cr 16

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